Improper Payments Information Act and Other Laws and Regulations

Bureau of the Comptroller and Global Financial Services
Report
November 17, 2014




Improper Payments Information Act, as Amended

The Improper Payments Information Act of 2002 (IPIA), Public Law No. 107-300, requires agencies to annually review their programs and activities to identify those susceptible to significant improper payments, as well as to conduct payment recapture audit programs. During 2010, the President signed into law the Improper Payments Elimination and Recovery Act (IPERA, Public Law No. 111-204), which amends the Improper Payments Information Act of 2002, and repeals the Recovery Auditing Act (Section 831 of the 2002 Defense Authorization Act, Public Law No. 107-107). In January 2013, the Improper Payments Elimination and Recovery Improvement Act of 2012 (IPERIA, Public Law No. 112-248) was signed into law and further amended IPIA, though it was not required to be fully implemented until fiscal year 2014. Further references in this disclosure to the term IPIA will imply IPIA, as amended by IPERA and IPERIA. Most significantly, IPERIA expanded the term payment to refer to all payments except intragovernmental transactions. It also codified OMB's ongoing efforts to develop and enhance the government's Do No Pay Initiative, which included the creation of a centralized Do Not Pay List for agencies to access prior to disbursing payments.

IPIA defines significant improper payments as annual improper payments in a program that exceed both 1.5 percent of program annual payments and $10 million, or that exceed $100 million, regardless of the error rate. Once those highly susceptible programs and activities are identified, agencies are required to estimate and report the annual amount of improper payments. Generally, an improper payment is any payment that should not have been made or that was made in an incorrect amount under statutory, contractual, and administrative or other legally applicable requirement.

IPIA, as Amended, Reporting Details

The Department defines its programs and activities in alignment with the manner of funding received through Appropriations, as further subdivided into funding for operations carried out around the world. For example, the Embassy Security, Construction, and Maintenance Appropriation is comprised of several programs for Improper Payment reviews. Two examples include the Short-term Residential Lease and Construction programs. The Congressional Budget Justification represents the Department's annual funding request to the Congress and provides important information about the Department's programs and activities, organizational performance targets relating to the Department's Strategic Plan, and the resources needed to achieve the Department's performance goals.

Risk assessments over all programs are done every three years. In the interim years, risk assessments evaluating programs that experience any significant legislative changes and/or significant increase in funding will be done to determine if the Department continues to be at low risk for making significant improper payments at or above the threshold levels set by OMB. The Department conducted a risk assessment of all programs and activities in 2013. As such, 2014 is an interim year.

Risk assessments of programs and activities involve an evaluation of the risk factors described in OMB Circular A-123 Appendix C, as well as consideration of the work performed in compliance with OMB Circular A-123 Appendix A, internal Department information regarding the operation of programs and activities, results of audits performed by the Office of Inspector General, the GAO, the Special Inspector General for Afghanistan Reconstruction, and other relevant information. Based on this series of internal control review techniques performed in 2013, the Department determined that none of its programs were risk-susceptible for making significant improper payments at or above the threshold levels set by statute. This conclusion is still relevant throughout 2014. However, because the Department identified 14 programs that experienced significant increases in funding and/or changes in legislation since the full risk assessment took place, the Department performed internal control techniques consistent with the prior year on these 14 programs. Based on these procedures as well as those performed on all programs in 2013, the Department determined that none of its programs in 2014 were risk-susceptible for making significant improper payments at or above the threshold levels set by OMB.

Recapture of Improper Payments Reporting

A number of improper payment activities, both preventative and recovery, exist for domestic and overseas payments at the Department, Bureau, post, and program levels to support IPIA efforts and ensure the integrity and accuracy of Department payments. The Bureau of the Comptroller and Global Financial Services (CGFS) has a two-tiered improper payment monitoring and review program that consists of activity performed by the Office of Claims (OC) and the Office of Oversight and Management Analysis (OMA). Improper payment reviews are performed initially by OC as an integral part of our post-payment review process, and secondly by OMA. While many agencies hire external recapture auditors to perform a secondary review, this function is performed more efficiently within the Department by OMA. Because the activity performed by OC is a post-payment (versus recapture payment) review process, those results are not considered recapture audits and are considered an activity outside of recapture audits. Because the OMA activity is secondary and consistent with a function that an external auditor would perform, for reporting purposes the OMA's activity is considered recapture. In addition, in 2014 CGFS Retirement Accounts Division (RAD) began reporting identified and confirmed overpayments as required by IPIA.

Overpayments Recaptured Outside of Payment Recapture Audits

Improper payment identification and collection are essential functions of the accounts payable process and the paying office's operations. As such, OC has established an internal debt management unit, whose primary mission is to identify and collect improper payments. Historically, this activity represented the majority of the Department's recapture results. However, starting in 2011, based on the revised IPIA guidance from OMB, this activity is classified and reported as overpayments recaptured outside of recapture payment audits activity. OC results represent the majority of the $41.1 million amounts shown as prior years' activity in the table entitled Payment Recapture Audit Reporting, while activity since 2011 has accumulated in the table entitled Overpayments Recaptured Outside of Payment Recapture Audits.

Overpayments Recaptured Outside of Payment Recapture Audits
Source of
Recovery
Amount Identified
(CY)
Amount Recovered
(CY)
Amount Identified
(PYs)
Amount Recovered
(PYs)
Cumulative Amount Identified
(CY+PYs)
Cumulative Amount Recovered
(CY+PYs)
CGFS Office of Claims (Vendor Payments) $4.9 million $5.9 million $37.9 million $35.9 million $42.8 million $41.8 million
CGFS Office of Claims (Employee Payments) $50.0 thousand $49.2 thousand $0 $0 $50.0 thousand $49.2 thousand
OIG $75.2 million $75.2 million $38.5 million $38.5 million $113.7 million $113.7 million
Annuity Payments $1.15 million $296 thousand $0 $0 $1.15 million $296 thousand
CY=2014, PYs=2013 and earlier except for annuity and employee claims payments

During 2014, OC's efforts identified and confirmed transactions totaling $4.9 million of actual duplicate/improper payments, of which we recovered $4.6 million, in addition to collecting $1.3 million of the prior year unrecovered balance of $1.9 million. Thus, total amounts recovered in 2014 (i.e. current year) were $5.9 million. At the end of FY 2014, the Department has collected all but $355 thousand of the current year identified amount and $637 thousand of the prior years' identified amount, resulting in the cumulative outstanding balance of approximately $1 million. Also, in 2014 the Department identified and confirmed employee claims transactions totaling $50 thousand of actual overpayments, of which we recovered $49.2 thousand. Thus, $800 remains to be collected in the upcoming fiscal year. As presented in the table entitled Overpayments Recaptured Outside of Payment Recapture Audits, in 2014 the Department's CGFS Retirement Account Division (RAD) identified and confirmed overpayment transactions totaling $1.15 million, of which $296 thousand has been recovered. At times, recovery can be delayed due to a debtor's request for an administrative review. The Department will continue efforts to collect the remaining 2014 unrecovered balance of $854 thousand. These overpayments occur for various reasons such as annuity reduction due to divorce, annuitant re-employment, and untimely notification of death. Since implementing the Do Not Pay Initiative requirements, RAD continues the use of the Do Not Pay Death Master File (DMF) on a pre-payment basis to better identify when annuitant deaths occur. This and other internal controls greatly assist RAD in preventing and managing improper payments.

Additionally, the Office of Inspector General conducted investigations spanning a breadth of content, including fraud, embezzlement, bribery and kickbacks, false statements, and employee misconduct. Recoveries obtained as a result of OIG investigations are also presented in the table entitled Overpayments Recaptured Outside of Payment Recapture Audits.

Payment Recapture Audit Reporting

CGFS incorporates various manual and automated data analysis techniques and processes to identify, validate and collect improper payments, including use of data mining software, manual sampling of internal payment records, U.S. Treasury taxpayer identification number matching, and sampling of vendors. Monthly, OMA conducts a query of domestic vendor payments. These payments represent the largest category of Department-made payments subject to IPIA recapture audit requirements, focusing on identifying potential improper and duplicate payments. Currently, these payments are reviewed on a monthly basis using IDEA - Data Analysis Software. An automated analysis is executed to run matches of vendor invoice numbers and payment amounts against current payment data and payments dating back to 2007. In addition to the automated IDEA analysis, in 2014 OMA expanded the manual quarterly Prompt Payment review of overseas payments to include domestic payments. These manual recapture audits validate elements such as vendor, payment amount, and ensure proper documentation exists to support sampled payments.

Payment Recapture Audit Reporting (Combined Program or Activity1)
Type of Payment Amount Subject to Review for Reporting
(CY)
Actual Amount Reviewed and Reported
(CY)
Amount Identified for Recovery
(CY)
Amount Recovered
(CY)
% of Amount Recovered out of Amount Identified
(CY)
Amount Outstanding
(CY)
% of Amount Outstanding out of Amount Identified
(CY)
Amount Determined Not to be Collectable
(CY)
Contracts $11.5
billion
$10.2
billion
$39,464 $38,262 97% $1,202 3% $0
Employee Claims2 $192.1
million
$7.8
million
$16,476 $7,241 44% $9,235 56.1% $0
Type of Payment % of Amount Determined
Not to be
Collectable out of Amount Identified
(CY)
Amounts Identified for Recovery
(PYs)
Amounts
Recovered
(PYs)
Cumulative
Amounts
Identified
for
Recovery
(CY + PYs)
Cumulative
Amounts
Recovered
(CY + PYs)
Cumulative Amounts Outstanding
(CY+PYs)
Cumulative Amounts Determined Not to be Collectable
(CY+PYs)
Contracts (continued) 0% $41.1
million
$41.1
million
$41.2
million
$41.2
million
$1,202 $0
Employee Claims (continued) 0% $0 $0 $16,476 $7,241 $9,235 $0

CY=2014, PYs=2013 and earlier

1 Represents the collective amounts reviewed, identified, and recovered. The CY amounts identified and recovered are shown by individual program in the following three tables. (back to text)

2 Administratively for Employee Claims the reporting period was April 1, 2013 to March 31, 2014. (back to text)


Payment Recapture Audit Targets
Program or Activity Type of Payment CY
Amount
Identified
CY
Amount
Recovered
CY
Recovery Rate
(Amount Recovered / Amount Identified)
CY + 1
Recovery
Rate Target
CY + 2
Recovery
Rate Target
CY + 3
Recovery
Rate Target
Diplomatic policy and support Contract $11,557 $11,557 100% 100% 100% 100%
Public diplomacy Contract $25,680 $25,680 100% 100% 100% 100%
ICASS Contract $1,025 $1,025 100% 100% 100% 100%
Worldwide Security Protection Contract $1,202 $0 0% 90% 100% 100%
Machine Readable Visa Employee Claim $1,538 $1,538 100% 100% 100% 100%
Worldwide Security Protection Employee Claim $1,790 $986 55% 90% 100% 100%
Other Diplomatic Employee Claim $1,909 $1,303 68% 90% 100% 100%
Residential Lease Employee Claim $389 $389 100% 100% 100% 100%
ICASS Employee Claim $7,925 $100 1% 90% 100% 100%
Overseas Employee Claim $2,193 $2,193 100% 100% 100% 100%
Diplomatic policy and support Employee Claim $526 $526 100% 100% 100% 100%
Public diplomacy Employee Claim $206 $206 100% 100% 100% 100%

Aging of Outstanding Overpayments
Program or Activity Type of
Payment
CY Amount Outstanding
(0-6 months)
CY Amount Outstanding
(6 months to 1 year)
CY Amount Outstanding
(over 1 year)
Worldwide Security Protection Contract $1,202 $0 $0
Worldwide Security Protection Employee Claim $804 $0 $0
Other Diplomatic Employee Claim $606 $0 $0
ICASS Employee Claim $7,825 $0 $0

Disposition of Recaptured Funds
Program or Activity Type of Payment Agency Expenses to Administer
the Program
Payment Recapture Auditor Fees Financial Management Improvement Activities Original Purpose Office of Inspector General Returned to Treasury
Diplomatic policy and support Contract $0 $0 $0 $11,557 $0 $0
Public diplomacy Contract $0 $0 $0 $25,680 $0 $0
ICASS Contract $0 $0 $0 $1,025 $0 $0
Machine Readable Visa Employee Claim $0 $0 $0 $1,538 $0 $0
Worldwide Security Protection Employee Claim $0 $0 $0 $986 $0 $0
Other Diplomatic Employee Claim $0 $0 $0 $1,303 $0 $0
Residential Lease Employee Claim $0 $0 $0 $389 $0 $0
ICASS Employee Claim $0 $0 $0 $100 $0 $0
Overseas Employee Claim $0 $0 $0 $2,193 $0 $0
Diplomatic policy and support Employee Claim $0 $0 $0 $526 $0 $0
Public diplomacy Employee Claim $0 $0 $0 $206 $0 $0

In 2014, OMA identified $16.4 thousand in employee claims recapture audit overpayments, of which $7.2 thousand was recovered. Thus, an outstanding balance of $9.2 thousand remains unrecovered for employee claims recapture audit activity. Collection efforts will continue on this balance as these accounts are aged less than one year. In addition, in 2014 OMA further expanded recapture efforts to include annuity payments. OMA focused its efforts reviewing annuitant payments that are calculated based on certain eligibility requirements. Specifically, OMA initiated a pilot recapture audit of payments to surviving children of annuitants requiring verification of school enrollment for payment. Regarding grant payments, each year the Department closely monitors activity of grantees of which the Department is the designated Federal Cognizant Agency, including follow-up with grantees regarding any disallowed costs identified on the grantees audit reports issued in compliance with OMB Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations. During 2014, OMA initiated a review of grant payments data made on behalf of the Department by the Department of Health and Human Services through their Payments Management System for inclusion in our recapture audit activity. Though grant payments are not currently included in the automated analysis using IDEA due to system and data limitations, OMA will continue to develop review techniques for grant payments in 2015.

Beginning in 2011, this activity represents the Department's recapture results, pursuant to revised IPIA guidance from OMB, as the Department concluded only this internal activity fits the definitions and purpose of the IPIA Recapture Audit program requirements. These results are presented in the table entitled Payment Recapture Audit Reporting.

For 2014, a total of $11.5 billion, comprised of $10.4 billion in domestic vendor payments and $1.1 billion in overseas vendor payments, were subjected to recapture audits. Of those amounts, domestic vendor payments totaling $10.4 billion and overseas payments totaling $183.8 million were reviewed, resulting in the identification of 7 transactions totaling $39,464 as improper payments (that are not duplicative of the results first identified by the Office of Claims). The Department has collected $38,262 of the current year identified amount, resulting in a recovery rate of 97 percent. In addition, for 2014, $192.1 million in employee claims were subjected to recapture audits. Administratively, we report as 2014 the period of April 1, 2013 to March 31, 2014. Of that amount, $7.8 million were reviewed, resulting in the identification of 33 transactions totaling $16,478 as improper payments. The Department has collected $7,241 of the current year identified amount, resulting in a recovery rate of 43.9 percent. The recaptured funds for both vendor and employees improper payments collected were returned to the originating appropriation. The Department performs analysis to determine the cause of improper payments and has determined the primary reasons are linked to vendor billing issues and initial approval for payment. Increased quality control processes by OC in both the payment generation and internal post-payment review processes have contributed to lower improper recapture audit amounts. Specifically, the majority of improper payments identified through recapture audits has already been identified by the Office of Claims, and as such, are reported in the Overpayments Recaptured Outside of Payment Recapture Audits table.

The CGFS automated duplicate or improper payment program using the domestic payment file for recapture audit analysis has proven to be a cost effective tool. The domestic file presently includes the majority of payments subject to IPIA requirements, such as domestic vendor payments. In 2005 and 2006, the Department contracted with an external firm to perform recapture audit activities. However, after 2006, the contracted firm determined it was not cost-effective to continue this function. CGFS realizes that additional recapture audit opportunities may exist and will continue to collectively assess areas of greater risk of improper and improper payments and implement recapture audit measures deemed cost-effective.

Agency Reduction of Improper Payments with the Do Not Pay Initiative

In 2014 the Department continued to utilize the Do Not Pay (DNP) initiative's Social Security Administration Death Master File (DMF) on a pre-payment continuous monitoring basis for all annuitant payments. At least twice each month, prior to processing the annuity roll, the Department's annuitant database is screened against the DMF to identify deceased annuitants. All matches are researched and if confirmed, payment to the annuitant is stopped prior to the monthly annuity payment run. In 2014, 187 thousand payments totaling $904.3 million were reviewed against the DMF and 128 payments totaling $481 thousand were stopped due to this internal agency initiative. This process has been successful in timely identifying deceased annuitants and ensuring these improper payments are not made. In addition, all annuity manual payments processed through Treasury's Secure Payment System are also reviewed through the Do Not Pay DMF online search prior to making the payment. For each manual payment, the Department maintains supporting documentation to show that a DMF match did not occur.

The Department also reviewed Do Not Pay potential erroneous payments provided by Treasury on a monthly basis. The Department was provided potential matches from Treasury disbursed payments which were adjudicated and results were reported to Treasury. During 2014, the Department adjudicated potential payment file matches from July 2013 through June 2014 totaling 1.6 million payments with a grand total of $10.4 billion. Two lists of potential matches were provided, one list comparing payments to the public Death Master File (DMF) of the Social Security Administration and one list comparing payments to General Services Administration's public Excluded Parties List System (EPLS). The DMF results were based on a social security number match of any payees who have been reported as deceased. During 2014, the Department received 39 potential erroneous payment matches to the public DMF file totaling $99 thousand. These payments were reviewed and all were deemed to be rightfully due to the deceased's estate. The EPLS results were a match of only the first and last name of the payee to the EPLS list. Since the Department was not able to obtain private EPLS list access during 2014, non-employee payments, in which a social security number or tax identification number was provided, were verified by researching the List of Excluded Individuals/Entities (LEIE) of the Office of Inspector General of the Department of Health and Human Services. Employees of the Department are subject to continuous monitoring to verify they are not included on the Excluded Parties List in order to maintain clearance levels and therefore, all payments to employees were considered valid. Potential matches which did not contain a social security number or tax identification number were sampled. All samples were fee refunds, thus not federally funded and considered valid. During 2014, the Department received 35,642 potential erroneous payment matches to the public EPLS file totaling $134.5 million. No erroneous payments were identified with this adjudication.

Implementation of the Do Not Pay Initiative to Prevent Improper Payments
  Number (#)
of Payments Reviewed for Improper
Payments
Dollars ($)
of Payments Reviewed for Improper
Payments
Number (#)
of Payments Stopped
Dollars ($)
of Payments Stopped
Number (#)
of Improper Payments Reviewed and
Not Stopped
Dollars ($)
of Improper Payments Reviewed and
Not Stopped
Annuity payment reviews with the DMF only 187 thousand $904.3 million 128 $481 thousand 0 0
Treasury provided reviews with the DMF only1 1.6 million $10.4 billion 0 0 0 0
Reviews with other databases2 1.6 million $10.4 billion 0 0 0 0

CY=2014, PYs=2013 and earlier

1 Treasury provided reviews include payments from July 2013 through June 2014. (back to text)

2 Reviews with other databases includes EPLS. (back to text)

With the deployment of the upgraded Do Not Pay database, the Department will be provided potential DMF and EPLS matches on a daily basis. The EPLS results will be based on the private EPLS which will include a match on social security number or tax identification number. This change will provide more validity to the potential matches received for adjudication. The Department plans to adjudicate these potential matches daily which will aid in the effort to recapture payments on a timely basis. Also, the Department has been working with Treasury and the Federal Reserve Bank to validate all active vendors in the Global Financial Management System with the DNP database on a periodic basis to identify 'Do Not Pay' vendors before payments are executed.

For non-Treasury disbursements, certifying officers verified payee information against the Office of Foreign Assets Control's (OFAC) list of Specially Designated Nationals (SDN). Also, during country integration to the Society of Worldwide Interbank Financial Telecommunication network the Department provided vendor lists associated with the given country to the Federal Reserve Bank. The Federal Reserve Bank verified none of the listed vendors were included on the OFAC's SDN list. Furthermore, each non-Treasury disbursement payment batch was verified against OFAC's SDN list before being sent to the intermediary bank and before the intermediary bank transferred the funds to local bank.

Sensitive Payments

The Department does not have programs determined risk-susceptible for making significant improper payments at or above the threshold levels set by OMB. However, in addition to the required annual IPIA reviews, Departments are also encouraged to conduct reviews of programs and activities that are prone to misinterpretation or misapplication of Federal guidelines and various sensitive payment areas. Sensitive payments are those where the dollar amounts involved are usually not significant, but the public disclosure of improper payments may result in significant criticism of the agency. The Department has identified several areas of sensitive payments for review. They include: Premium Class Travel, Executive Compensation, Representation Costs, Speaking Honoraria and Gifts, and Executive Perquisites. In past years, the American Recovery and Reinvestment Act payments were among those that were carefully reviewed. Premium Class Travel payments are reviewed annually, and the other areas are reviewed on a rotating schedule depending on their level of risk and sensitivity.

Premium Class Travel Reviews

The Department's mission is conducted throughout the world and requires extensive travel, sometimes of a significant duration. Because of the high volume of travel, the Department has made concerted efforts to monitor if official travel has adhered to Government-wide and Department regulations for premium class travel.

The Department selected a random sample and supporting documentation was reviewed. During 2014, there have been no instances where evidence was found that a business class travel payment was unapproved and needed to be recovered, or where the travelers flying business class were found to be ineligible. However, there have been instances where proper supporting documentation was not readily available. Those errors represent an error rate of 12 percent ($54,885) in 2014 and 8 percent ($56,442) in 2013. OMB requires agencies to report improper payment errors based on three categories of errors: documentation and administrative errors, authentication and medical necessity errors, and verification errors. All Department errors found each year were attributable to documentation and administrative errors. During 2015, the Department will undertake efforts to correct the deficiencies noted during the 2014 review.

Federal Civil Penalties Inflation Adjustment Act

The Federal Civil Penalties Inflation Adjustment Act of 1990 established annual reporting requirements for civil monetary penalties assessed and collected by Federal agencies. The Department assesses civil fines and penalties on individuals for such infractions as violating the terms of munitions licenses, exporting unauthorized defense articles and services, and valuation of manufacturing license agreements. In 2014, the Department assessed $30 million in new penalties against two companies, and collected $39.4 million of outstanding penalties from seven companies. In addition, the total outstanding balance due was reduced by $23.6 million as a result of adjustments associated with remedial compliance measures. The balance outstanding at September 30, 2014, was $25 million.

Debt Management

Outstanding debt from non-Federal sources (net of allowance) decreased from $81.3 million at September 30, 2013 to $48.1 million at September 30, 2014. Civil Monetary Penalties decreased by $33 million at September 30, 2014, resulting in a decrease overall to the non-Federal source figures.

Non-Federal receivables consist of debts owed to the International Boundary and Water Commission, Civil Monetary Fund, and amounts owed for repatriation loans, medical costs, travel advances, and other miscellaneous receivables.

The Department uses installment agreements, salary offset, and restrictions on passports as tools to collect its receivables. It also receives collections through its cross-servicing agreement with the Department of the Treasury (Treasury). In 1998, the Department entered into a cross-servicing agreement with Treasury for collections of delinquent receivables. In accordance with the agreement and the Debt Collection Improvement Act of 1996 (Public Law 104-134), the Department referred $2.5 million to Treasury for cross-servicing in 2014. Of the current and past debts referred to Treasury, $1.1 million was collected in 2014.

Receivables Referred to the Department of the Treasury for Cross-Servicing
  2014 2013 2012
Number of Accounts 997 1,189 1,189
Amounts Referred (dollars in millions) $2.5 $2.8 $3.6
Amounts Collected (dollars in millions) $1.1 $1.1 $0.9

Prompt Payment Act

Timeliness of Payments

Bar chart summarizing timeliness of Department of State payments for fiscal years 2012 to 2014. Values are as follows:
FY 2012:
   On Time: 98%.
   Late: 2%.
FY 2013:
   On Time: 98%.
   Late: 2%.
FY 2014:
   On Time: 98%.
   Late: 2%.

The Prompt Payment Act (PPA) requires Federal agencies to pay their bills on time. PPA assesses an interest penalty against Federal agencies that do not pay their vendors timely as required by law. In 2014, the Department timely paid over 98 percent of the 549,798 payments subject to PPA regulations. The following chart reflects the timeliness of the Department's payments from 2012 through 2014. During 2014, the Department paid $281 thousand in interest penalties, compared to $226 thousand in 2013, a 24 percent increase. A major contributing factor to the increase in interest penalties was the high staff turnover involved in the invoice certification process during a four-month period.

Electronic Payments

The payments made through Electronic Funds Transfer (EFT) were over 98 percent of the total payments made for domestic and overseas payments. Domestic operations accomplished over 98.8 percent of its payments with EFT this year. Overseas operations have a slightly lower EFT percentage (97.7 percent) than domestic operations due to the complexities of banking operations in some foreign countries. For 2014, approximately 3.5 million payments were disbursed for the Department of State.